A “Conversion” is defined in VRT legislation S130 FA 1992 as follows:
” ‘conversion’ means the modification of the vehicle, which, in relation to –
- a registered vehicle, means the modification of the vehicle in such manner that any of the particulars recorded for the purpose of its registration are altered,
- an unregistered vehicle, means the modification of the vehicle in such manner that any of the particulars recorded for the purpose of its type-approval, or, if it has been registered previously in another jurisdiction, for the purpose of the most recent such registration, are altered”.
There are 3 separate scenarios that are outlined below:
- Pre Registration Conversion of ‘New’ unregistered vehicles.
For vehicles that are new and have been converted, but have not been registered in Ireland or any other jurisdiction.
- Pre Registration Conversion of vehicles previously registered in another jurisdiction.
For vehicles that have been registered in a jurisdiction other than Ireland and have been converted prior to registration in Ireland.
- Post Registration Conversions (Converted Irish Registered Vehicle).
For vehicles that have already been registered in Ireland, and have been issued an Irish Registration number, and which are subsequently converted.
- Suitably Qualified Individual (SQI)
- EU Vehicle Categories
- EU Body Works
- Motor Caravans
- Conversion Forms
Note: ‘Registration’ refers to a vehicle being registered in Ireland unless otherwise specified.
Pre Registration Conversion of ‘New’ unregistered vehicles.
All new vehicles of EU vehicle categories M1, M2, M3, N1, N2, N3 and L require European Community Whole Vehicle Type-Approval ECWVTA, or national type-approval in order to be registered in Ireland. This approval documentation is generally in the form of a Certificate of Conformity. Full details of the requirements of EU Type Approval can be found on the RSA website here.
Vehicles which have not been previously registered in any jurisdiction, but have been converted/modified since the issuing of the Certificate of Conformity documentation, must have the converted/modified vehicle certified/approved by a National Approval Authority.
The National Standards Authority of Ireland (NSAI) is the Irish national approval authority. Where the documentation was issued by another approval authority, it must be approved by the NSAI.
Further details about the NSAI including contact details can be obtained on their website: www.nsai.ie.
An unregistered and converted vehicle presented for registration at an NCTS centre must be accompanied by the relevant approval documentation.
Where the conversion has been made to an unregistered birth-certed vehicle, the amended Statistical Code may now be entered on ROS.
Pre Registration Conversion of vehicles previously registered in another jurisdiction.
In order to have a previously registered, converted vehicle registered in Ireland, the vehicle owner must present the Declaration of Conversion and related Suitably Qualified Individual declaration to the NCTS when declaring a vehicle of this type for registration. This form should be used in cases where the following vehicle characteristics have changed:
- the EU vehicle category,
- the number of seats,
- the number of seatbelt fittings,
- the EU Body Work code,
- the mass in service,
- the number of doors, and/or
- the number of windows.
The owner declaration on the Declaration of Conversion form, stamped by the SQI and an accompanying declaration by the SQI on headed paper must accompany the vehicle (in addition to the normal paperwork – original registration certificate etc) when presented for a pre-registration examination.
- Please see https://www.ncts.ie/1145 for documents which must be brought to the NCTS when presenting a vehicle for registration.
- In addition, the total cost of conversion in Euros including VAT must be supported with a list of invoices/receipts showing dates and amounts.
Post Registration Conversions (Converted Irish Registered Vehicle).
DECLARATION TO REVENUE IS NOT REQUIRED IN MOST CASES
- Declaration is not required if the Vehicle Registration Certificate at item J1 (VRT vehicle category) shows “A”.
- Declaration is only required if the Vehicle Registration Certificate at J1 shows “B” or “C” or “D” or is blank, and
- seats have been added and the new total including the driver is 9 seats or less;
- had 10 seats or more, seats have been removed and the new total including the driver is 9 seats or less;
- converted to motor caravan; declaration is not required however if registered in Ireland as a car or MPV or other EU category M1 vehicle, see notes below.
Only if 1, 2 or 3 above is the case, the vehicle owner must post the Declaration of Conversion and the related Suitably Qualified Individual declaration, and other supporting documents, to: FREEPOST, Central Vehicle Office, Revenue Commissioners, Rosslare Harbour, Co. Wexford.
All Declarations should be posted together with the following Supporting Documents:
- a copy of the Vehicle Registration Certificate (both sides),
- invoice(s) showing the costs of conversion, and
- in the case of a Motor Caravan, photographs showing the full interior (minimum of 6 photos, at least one of which should be taken from the front of the living area looking rearward and one from the rear of the living area looking forward such that they provide a good overview of the layout of the living accommodation) and exterior (minimum of 4 photos at least one of which includes the registration plate of the vehicle).
- Declaration is not required if vehicle is registered as car/MPV or other M1 vehicle.
Suitably Qualified Individual
The conversion must be certified by a Suitably Qualified Individual (SQI).
A Suitably Qualified Individual (SQI) must have the appropriate facilities and equipment to conduct the examination and complete the certification. A SQI must have:-
- an Engineering/Technical Qualification (Level 7 or higher accredited courses) or appropriate accreditation with Engineers Ireland or the Institute of Automotive Engineer Assessors
- a minimum of 5 years experience of working in a suitable technical environment (preferably Automotive or Engineering Environment)
- access to adequate facilities to carry out a thorough vehicle examination, and
- appropriate professional indemnity insurance,
or: must be a National Standards Authority of Ireland approved facility (Approved Test Centre or Approved Workshop for Conversion of Vehicles for Disabled Drivers).
 See Engineers Ireland, Accredited Courses
 Chartered or Associate Engineer
 Member or Incorporated Member.
Proposal to Convert from EU Category M1 to N1
Where it is proposed to change a vehicle’s EU category from M1 to N1, the masses and dimensions must be confirmed by a National Standards Authority of Ireland (NSAI) Approved Test Centre whose scope covers – ‘Test: 48. Masses and Dimensions (not passenger cars)’.The dimensions must be measured by the laser measuring device and computed by the software approved by the NSAI for the taking of such measurements. From 1 November 2016 this must be confirmed in the declaration of conversion documents. Vehicles that do not meet the criteria for EU Category N1 will be deemed to be M1 vehicles.
Please note that no vehicle will be registered or recorded as N1 from 1 November 2016 unless there is a suitable confirmation from an Approved Test Centre.
- A list of NSAI ATCs and their scope is available here: http://www.nsai.ie/Our-Services/Certification/Automotive-Certification/Type-Approval/Approved-Test-Centers.aspx
- Revenue may require ATC Test 48 masses and dimensions certification in other circumstances.
EU Vehicle categories
The European Commission adopted Regulation (EU) No. 678/2011 on 14th July 2011. This regulation replaces Annex II of Directive 2007/46/EC. Declarants should familiarise themselves with the general definitions, criteria for vehicle categorisation, vehicle types and types of body work set out in the Annex to the Regulation.
- Category M1:- vehicle designed and constructed for the carriage of passengers and comprising no more than eight seating positions in addition to the driver’s seating position; no space for standing passengers.
- Category M2:- vehicle designed and constructed for the carriage of passengers, comprising more than eight seating positions in addition to the driver’s seating position, and having a maximum mass not exceeding 5 tonnes; may have space for standing passengers.
- Category M3:- vehicle designed and constructed for the carriage of passengers, comprising more than eight seating positions in addition to the driver’s seating position, and having a maximum mass exceeding 5 tonnes; may have space for standing passengers.
- Category N1:- vehicle designed and constructed for the carriage of goods and having a maximum mass not exceeding 3.5 tonnes.
- Category N2:- vehicle designed and constructed for the carriage of goods and having a maximum mass exceeding 3.5 tonnes but not exceeding 12 tonnes.
- Category N3:- vehicle is a vehicle designed and constructed for the carriage of goods and having a maximum mass exceeding 12 tonnes.
EU Body Work Codes
|EU Category||Body Work Code||Description|
|M2, M3||CA||Single deck|
|M2, M3||CB||Double deck|
|M2, M3||CC||Articulated single deck|
|M2, M3||CD||Articulated double deck|
|M2, M3||CE||Low-floor single deck|
|M2, M3||CF||Low-floor double deck|
|M2, M3||CG||Articulated low-floor single deck|
|M2, M3||CH||Articulated low-floor double deck|
What is a Motor Caravan/Motor Home?
To be deemed a motor caravan/motor home, a vehicle must be a special purpose Category M vehicle (EU Body Work of SA) and must be constructed to include living accommodation which contains at least the following equipment:
- seats and table,
- sleeping accommodation which may be converted from the seats,
- cooking facilities, and
- storage facilities.
This equipment must be rigidly fixed to the living compartment; however, the table may be designed to be easily removable.
The primary purpose of a Motor Caravan is to provide mobile living accommodation. The living accommodation space should be of a size and area to allow a comfortable living environment for a person or persons for an extended period of time. This would generally require the whole of the rear compartment of a vehicle, behind the driver’s compartment, to be utilised for this purpose, such that the occupant/s have ready access to storage, preparation, cooking, eating, sleeping and related facilities from within the living accommodation space. (It would be expected that the living accommodation space in the rear compartment would have side windows and, where cooking is by means of gas, a Gas Installer Certificate is available). Comfortable living accommodation should comprise an area where a person (of average height) could move around in a standing position.
Coach-built or Factory Built Motor Caravans
Purpose built Motor Caravans fulfill this requirement for mobile living accommodation by virtue of their design, construction and Type Approval, and contain all of the fittings and fixtures one would expect to find in the living accommodation space of a Caravan.
Vehicles intended to be converted to a Motor Caravan must fulfill the requirement to provide mobile living accommodation, and the rear compartment must be modified sufficiently to contain all the fittings and fixtures reasonably expected of a Motor Caravan.
Modifications that do not significantly alter the interior of the rear compartment to include fittings and fixtures (for example, removal of seats to accommodate a table), or which modify only the boot storage area to provide storage fittings or exterior access to cooking facilities, are not regarded as Motor Caravans.
These modified vehicles can be referred to as a Day Van, and will generally only contain the bare essentials required for a day out, with perhaps exterior cooking facilities. In this regard, Day Vans will not be classified as Motor Caravans for VRT purposes. Revenue will not accept a candidate in which the preparation, cooking, storage or other facilities are reasonably accessible only from outside the vehicle.
Where a Passenger Vehicle (M1) is converted, retaining its passenger carrying capacity, but does not fulfill the criteria of a Motor Caravan, it will retain its original EU Classification.
Where a Commercial Vehicle (N1, N2 or N3) is converted, increasing its passenger carrying capacity, but does not fulfill the criteria of a Motor Caravan, it may be classed as a Passenger Vehicle (M1). This will mean an increased VRT liability based on the CO2 emissions of the vehicle.
Motor caravans/motor homes registered on or after 1 January 2011, will be charged VRT at 13.3% of the open market selling price of the vehicle at the time of registration.
Where a declaration of a conversion of a vehicle to a Motor Caravan is being made, photographs showing the full interior (minimum of 6 photos, at least one of which should be taken from the front of the living area looking rearward and one from the rear of the living area looking forward such that they provide a good overview of the layout of the living accommodation) and exterior (minimum of 4 photos at least one of which includes the registration plate of the vehicle) must be included with the completed declaration form.
Requirements for registration of a vehicle as an ‘Ambulance’
“Ambulance” is defined in EU Commission Regulation Number 678/2011, Annex I, part A, Section 5.3, as follows:
Ambulance (EU bodywork type “SC”)
A vehicle of category M intended for the transport of sick or injured persons and having special equipment for such purpose. The patient compartment shall comply with the technical requirements of Standard EN 1789:2007 on “Medical vehicles and their equipment – Road ambulances” with the exception of Section 6.5 “List of equipment”.
CEN 1789: 2007 is the European Standard for ambulances. This specifies the design, testing, performance and equipping of road ambulances. This standard is applicable to vehicles capable of transporting at least one person on a stretcher.
There are four types of Road Ambulances as follows:
- Type A: Patient Transport Ambulance
Road Ambulance designed and equipped for the transport of patients who are not expected
to become emergency patients.
- Type A1: suitable for the transport of single patient
- Type A2: suitable for the transport of one or more patient(s) (on stretcher(s)
- Type B: Emergency Ambulance
Road Ambulance designed and
equipped for the transport, basic treatment and monitoring of patients.
- Type C: Mobile Intensive Care Unit
Road Ambulance designed and
equipped for the transport, advanced treatment and monitoring of patients.
Basic Requirements to obtain ambulance classification:
- EU Bodywork Code of ‘SC’ on Certificate of Conformity, Individual Vehicle Approval or NSAI approved Test Centre certification. ATC Certification should also include a separate statement that the vehicle meets the requirements of CEN 1789:2007.
- Permanent Bulkhead/Partition Wall separating the Driver’s compartment from the Passenger Compartment, with 1/2 windows. Door may be fitted, but where it is, it shall not be possible to drive the vehicle with the door in the open position.
- Permanent Stretcher position, accommodating a main stretcher/undercarriage (stretcher conforms to standard EN 1865).
- Minimum distance of 1,100mm from floor of stretcher position to ceiling of interior.
- 12V connections in passenger compartment, utilising a permanent power supply, separate from the basic vehicle electrical system. The minimum number of connections is outlined below:
|Type of Road Ambulance||Minimum Number of connections|
- A communication system consisting of a radio transceiver and internal communication system between the driver and patient compartment.
- Exterior Body Colour – White or Yellow. If white is base colour, additional florescent yellow or red should be used on external surface of the vehicle.
- Ceiling, side walls and doors of patient’s compartment shall be lined in a non-permeable material, resistant to disinfectant
- Floor coverings will provide adequate grip, and be durable and easy to clean.
- Visual and Audible Warning System – Optional for Type A ambulances
These are only some of the requirements for a vehicle to be classified as an ambulance at the time of registration in the State or upon declaration of a post-registration conversion. There are many other criteria set down in CEN 1789:2007. Revenue must be satisfied that the criteria have been fulfilled even if the vehicle has been previously registered as an ambulance in another state. Revenue reserves the right to refuse registration as an ambulance if it considers that the vehicle presented does not meet the required criteria. It is unlikely that an estate car or MPV will have the potential to qualify as an ambulance).
Further queries about the exact requirements and dimensions required for a vehicle to be classified as an ambulance should be directed to the National Standards Association of Ireland (NSAI) regarding Irish Standard I.S. EN 1789:2007 + A1:2010 : Medical vehicles and their equipment – Road ambulances.
The ‘Declaration of Conversion’ form and the ‘Suitably Qualified Individual’ declaration are part of the same document, and are available at: Vehicle Registration Tax Forms
Information provided courtesy of the Revenue Commissioners under a Creative Commons Attribution 4.0 International (CC BY 4.0) licence